A.M. No. MTJ-00-1333. November 15, 2000. Lamberto P. Villaflor vs. Judge Romanito A. Amatong.
FACTS:

Complainant Lamberto Villaflor was the defendant in an ejectment case (Civil Case No. 20555) before respondent Judge Romanito Amatong’s Metropolitan Trial Court (MeTC), Branch 53, Kalookan City. The MeTC ruled against Villaflor, ordering him to vacate the property. This decision became final and executory. Villaflor subsequently filed a separate action for annulment of title and judgment with the Regional Trial Court (RTC), which was dismissed. He appealed this RTC dismissal to the Court of Appeals (CA) in CA-G.R. CV No. 50623. While this appeal was pending, the plaintiff in the ejectment case, Biyaya Corporation, moved for execution and demolition before respondent judge’s MeTC.
Despite Villaflor’s opposition, Judge Amatong issued a writ of demolition. Villaflor then secured a Temporary Restraining Order (TRO) from the Court of Appeals on December 27, 1996, expressly enjoining the demolition. Notwithstanding the TRO, Judge Amatong issued an order on January 9, 1997, directing the sheriff to implement the demolition, which was carried out on January 10, 1997. The Court of Appeals later found Judge Amatong guilty of contempt for this act and fined him. Villaflor then filed this administrative complaint against the judge for grave abuse of authority, serious misconduct, and ignorance of the law.

ISSUE

Whether respondent Judge Amatong is administratively liable for issuing the demolition order in defiance of a Temporary Restraining Order issued by the Court of Appeals.

RULING

Yes, respondent Judge Amatong is administratively liable. The Supreme Court found that his act of ordering the demolition despite full knowledge of the Court of Appeals’ TRO constituted grave abuse of authority. The legal logic is clear: a Temporary Restraining Order issued by a higher court is a legal command that must be respected and obeyed by all lower courts and their officers. Respondent judge’s defense—that he believed the TRO was ineffective because it was addressed to the defendants in the CA case (including Biyaya Corporation) and not specifically to him as a judge—was untenable. The TRO was issued in the very case where he was impleaded as a party-respondent in his official capacity. His receipt of the TRO and his participation in the CA proceedings established his awareness of the order.
The Court emphasized that judges are mandated to obey the orders of superior courts. Disregarding such an order undermines judicial hierarchy and the orderly administration of justice. While the Court of Appeals had already punished him for contempt, this did not preclude separate administrative proceedings, as the purposes differ: contempt vindicates the court’s authority, while administrative discipline addresses the judge’s fitness for office. Considering his compulsory retirement and the prior contempt penalty, the Supreme Court tempered justice with mercy. Instead of the Court Administrator’s recommended fine of P50,000, the Court imposed a fine of P20,000, to be deducted from his retirement benefits, for grave abuse of authority.